Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Under Hybrid Annuity Mode (HAM) for National Highway Projects, concessionaire constructs new road and provides Operation & Maintenance over 15-17 years with payment staggered over years. HAM contract is single contract for construction and O&M, cannot be split into separate contracts. Payment is continuous supply of services u/s 2(33). Time of supply is date of invoice or receipt of payment, whichever is earlier, if invoice issued within prescribed period u/s 31(5). If invoice not issued within prescribed period, time of supply is date of provision of service or receipt of payment, whichever is earlier, with date of provision deemed as due date of payment. Tax liability arises at time of invoice or receipt of payment, whichever is earlier. Interest component in annuity/instalment is includible in taxable value u/s 15(2)(d).
Under Hybrid Annuity Mode (HAM) for National Highway Projects, concessionaire constructs new road and provides Operation & Maintenance over 15-17 years with payment staggered over years. HAM contract is single contract for construction and O&M, cannot be split into separate contracts. Payment is continuous supply of services u/s 2(33). Time of supply is date of invoice or receipt of payment, whichever is earlier, if invoice issued within prescribed period u/s 31(5). If invoice not issued within prescribed period, time of supply is date of provision of service or receipt of payment, whichever is earlier, with date of provision deemed as due date of payment. Tax liability arises at time of invoice or receipt of payment, whichever is earlier. Interest component in annuity/instalment is includible in taxable value u/s 15(2)(d).
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